{"operation":"document","citation":"PI-82-007","title":"Railroad Commission of Texas/Gas Utilities Division — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1982-05-06","effective_on":null,"summary":"PI-82-007 response to Railroad Commission of Texas/Gas Utilities Division concerning 192.625.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-82-007.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-82-007.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-82-007","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1982/PI82007.pdf","body":"<<<PAGE 1>>>\n\nMr. M. L. Fegenbush, Jr.\nDirector, Railroad Commission\nof Texas/Gas Utilities Division\nCapitol Station - P. O. Drawer 12967\nAustin, Texas 78711\nDear Mr. Fegenbush:\nThe enclosed interpretation has been issued in response to the several questions in your letter of\nMarch 11, 1982, regarding application of §192.625(b) to a pipeline serving an industrial customer\nand regarding the classification of a pipeline as transmission line or main.\nSincerely,\nMelvin A. Judah\nActing Associate Director for\nPipeline Safety Regulation\nMaterials transportation Bureau\nEnclosure\nDB\nC:\\WP51\\INTERPRT\\192\\625\\82-05-06\n1\n\n<<<PAGE 2>>>\n\nNo. 82-3\nDate: May 6, 1982\nDEPARTMENT OF TRANSPORTATION\nRESEARCH AND SPECIAL PROGRAMS ADMINISTRATION\nMATERIALS TRANSPORTATION BUREAU\nPIPELINE\n_________________________________________________________________\nSAFETY REGULATORY INTERPRETATION\nNOTE:A\n_________________________________________________________________\npipeline safety regulatory interpretation applies a particular rule to a\nparticular set of facts and circumstances, and, as such, may be relied upon\nonly by those persons to whom the interpretation is specifically addressed.\nSECTION: §§192.3 and 192.625(b)\nSUBJECT: Odorization of gas in a transmission line\nFACTS: I. An industrial customer received unodorized gas from a pipeline\nwhich operated at greater than 20 percent SMYS, passed through\nclass 1 and 2 locations, prior to May 5, 1975. The customer used\nthe gas for purposes and processes which did not require not would\nhave been affected by a malodorant additive. In 1979, the customer\nbegan hydrogen production which required unodorized gas, in that,\nmalodorant sulfur compounds severely affect catalyst activity.\nDuring 1980, it was determined that the class location along the\npipeline from the end and upstream for several miles had changed\nto class 3.\nQUESTION 1: Is the pipeline, in the class 3 locations, exempt from odorization?\nINTERPRETATION: The facts presented indicate that prior to May 5, 1975, the line in question\nwas a transmission line because it operated above 20 percent of\nSMYS. If the line is still properly classified as a transmission line,\nthe new class 3 portion of the line may qualify under\n§192.625(b)(3) for an exemption from the odorization requirement\nif the line is a lateral transmission line transporting gas to a \"large\nvolume customer\" with at least 50 percent of the length of line in\nclass 1 or 2 areas. By prior interpretation, a \"large volume\nDB\nC:\\WP51\\INTERPRT\\192\\625\\82-05-06\n2\n\n<<<PAGE 3>>>\n\ncustomer\" is in effect a \"distribution center\" for purposes of\nclassifying a pipeline as a \"transmission line\" under the definition of\nthat term is §192.3, and the term \"large volume customer\" is used\nconsistently here in applying §192.625(b). The class 3 portion\nwould not qualify for an exemption under the industrial plant\nprovision of §192.625(b)(2)(iv) because the current condition under\nwhich odorants are said to be detrimental arose after May 5, 1975.\nQUESTION 2: If there are 30 other customers along the pipeline not requiring\nunodorized gas, does the one which requires unodorized gas govern\nthe determination?\nINTERPRETATION: The exclusion of a class 3 pipeline from the odorization requirement\ndepends on whether the pipeline is a transmission line that falls\nwithin one of the exemption provisions of §192.625(b). The\nnumber of customers along a transmission line that are not troubled\nby receiving odorized gas is not a factor in applying §192.625(b).\nThus, for purposes of §192.625(b)(2) or (b)(3), only one customer\ncan qualify to exempt the entire upstream class 3 or 4 portion or\nportions of the line from the odorization requirement, even though\nin the case of paragraph (b)(2), the customer receives gas via a\nservice line connected to the transmission line. Any of the\ncustomers along an unodorized transmission line that receive gas\nvia a service line would have to be supplied odorized gas under\n§192.625(a).\nQUESTION 3: Is it necessary that the process requiring unodorized gas was\nperformed before May 5, 1975, or just that unodorized gas was\nserved before May 5, 1975, to create an exemption under\n192.625(b)(2)?\nINTERPRETATION: This question is answered in the answer to Question I.1. Amendment 192-\n21 (40 FR 20279) which established §192.625(b)(2) makes it clear\nthat the exemptions were intended to remedy existing problems and\nwere not intended to apply to future conditions. Similar but new\nproblems may be handled under the waiver process of section 3 of\nthe Natural Gas Pipeline Safety Act of 1968.\nFACTS: II. A pipeline has been called a transmission line, but through the\nyears numerous customers have been added and population density\nhas increased along the line.\nDB\nC:\\WP51\\INTERPRT\\192\\625\\82-05-06\n3\n\n<<<PAGE 4>>>\n\nQUESTION 1: When and/or under what conditions would this pipeline become a\ndistribution main?\nINTERPRETATION: The classification of a pipeline as a transmission line or main is determined\nby applying the definitions under §192.3. Under the definition of\n\"transmission line,\" the number of customers along a line is not one\nof the three conditions that qualify a pipeline as a transmission line.\nThus, regardless of the number of customers added to a\ntransmission line during its life, it remains a transmission line as lone\nas it continues to meet any of the qualifying conditions. If a gas\npipeline no longer qualifies as a transmission line and it is not a\ngathering line, then according to the definitions, it is a distribution\nline and a \"main\" if it serves more than one customer.\nQUESTION 2: Does it make difference if all of the customers ar large industrial\ncustomers, located in a densely populated area?\nINTERPRETATION: In accordance with the definition of \"transmission line,\" the addition of\nlarge industrial customers to a line is not a reason to reclassify the\nline as a main.\nMelvin A Judah\nActing Associate Director for\nPipeline Safety Regulation\nMaterials Transportation Bureau\nDB\nC:\\WP51\\INTERPRT\\192\\625\\82-05-06\n4","truncated":false,"body_characters":6032}